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ASIC

Accreditation

Handbook

ASIC

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CONTENTS 1 ASIC Officers, Advisory Board and Office Staff 1

2 Introduction 3

3 Accreditation 6

Introduction

The Accreditation Process Accreditation Decisions

Continuing Accreditation

Annual Reports

The Accreditation Committee.

4 Inspection Schedule 12

Introduction Areas of Operation

- A Premises and Health and Safety

- B Management and Staff Resources

- C Learning and teaching; Course Delivery - D Quality Assurance and Enhancement

- E Student Welfare

- F Qualifications and Awards - G Marketing and Student Recruitment

- H Compliance with UK Border Agency (UKBA) Regulations and

Reporting Mechanisms

5 Complaints 15

Introduction

How ASIC deals with complaints

6 Appeals 17 Introduction

Procedures

7 Fees and Expenses for Inspection Visits and Accreditation 19

Application for a New Accreditation

Interim Visits Annual Accreditation Fee

Payment of Fees and Expenses

Appendices

1. Excerpt from the Register of Education and Training Providers in the UK. 21

2. ASIC Website 22 3 Useful Web sites and Contact Points 23

4. Note on Plagiarism 25

5. Code of Ethics – Colleges 27

6. Code of Ethics – Education Representatives 29 7. Agreement for the Recruitment of International Students 31

1

1. ASIC Officers, Advisory Board and Office Staff

Officers: Chief Executive Mr Maurice K Dimmock

Head of Accreditation Professor John Wilson

Accreditation Manager Mr Lee Hammond

Senior Inspector Professor Don Cassells

Qualifications Advisor Dr Lawrence Watson

Accreditation Advisor Mrs Christine Wilson

Office Staff: Geoff Boston General Manager

Liesle Hattan Accounts Manager

Barry Wadrop Applications Manager

Andrew Robinson Communications Manager

Inspectors: Senior Inspector &

Health & Safety Advisor Mr Mike Coulson

Senior Inspector Professor Elizabeth Gillott

Mr David Straughan ASIC Inspector

Mr Peter Casey ASIC Inspector

Mr David Nixon ASIC Inspector

Rev Pete Spence ASIC Inspector

Rev Jim Wright ASIC Inspector

Mrs Nicole Brown ASIC Inspector

Mrs Nicola Nobes ASIC Inspector

Dr Dave Taylor ASIC Inspector

Mr Graham Minshaw ASIC Inspector

Mr Graeme Ronald ASIC Inspector

Office Contact Details: 13 Yarm Road Tel: 01740 617 920

Stockton on Tees Fax: 01740 617 929

TS18 3NJ

ASIC Advisory Board:

An Advisory Board has been established comprising those people who can bring

added value to ASIC in terms of the advice and guidance they can provide on

improving the services of ASIC to its Colleges.

Those who have agreed to act in this capacity include:

Mr Michael Elms (CEO of Hotcourses),

Mr John Lyons (Chartered Account),

Mr Jeremy Spooner (Barrister at Law),

Mr Mike Coulson (Health and Safety Officer)

Mr David Straughan (Internal Audit)

Mr Peter Spence (Clergyman)

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It is hoped that representatives from organisations such as the following will also

agree to act in this capacity:

The Border and Immigration Agency; Ofsted; UKCISA; UCAS; Sponsors

Management Unit of the Home Office and UKNARIC.

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2. Introduction

Following widespread and increasing concern over the behaviour of some colleges*

in the private sector, which largely cater for international students, the Government

recently identified the need for a more rigorous system for accrediting colleges

involved in recruiting international students. Accordingly, a proposal for the

mandatory accreditation of education providers, wishing to bring international

students into the UK, was included in the Government’s Command Paper “A Points

Based System: Making Migration Work for Britain”.

In response to this proposal, the Quality Study Abroad Network (QISAN) together

with a number of professional practitioners with considerable experience in recruiting

international students for universities, further education colleges and schools/EFL

colleges and in establishing collaborative arrangements between overseas institutions

and UK partners, decided to establish an embryo accrediting body, namely the

Accreditation Service for International Colleges (ASIC).

Given their collective experience, the members of this group were well aware of:

The existence of colleges, which appeared to focus largely on bringing into the

UK as potential students young people, whose main aim is to become an

illegal economic immigrant,

Colleges which, although genuine and sometimes accredited educational

institutions, provided their students with a poor experience, sometimes placing

them on inappropriate programmes and offering qualifications, which were not

formally recognised,

Quite reputable colleges, and indeed some universities, which were not well

prepared to cater for all of the needs of international students,

A number of colleges, which fabricated details of attendance on class

registers and which did not inform the Home Office of students who

disappeared from their courses,

The difficulty that the Entrance Clearance Officers, students and their parents

have in finding accurate information about the colleges.

ASIC, therefore, fully recognises the pressing need for a robust and transparent

approach to ensuring that colleges, to the best of their ability, only recruit genuine and

appropriately qualified students and that they provide the best possible student

experience in terms of the students achieving their maximum academic potential

whilst having their social and pastoral needs fully addressed. In recent years, bodies

such as the Quality Assurance Agency, the British Accreditation Council and FEQC

have monitored higher and further education providers in these respects, but members

of the group have visited several smaller, especially private, colleges and noted that

they fall short of what is acceptable.

A related issue of concern is the behaviour of some education agents/representatives,

who do not provide students with an acceptable, ethical advisory service, in terms of

their giving poor, ill-informed advice and charging high fees.

* Throughout this Handbook the term college has been used to include all relevant educational

institutions, whatever their name.

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In response to this unsatisfactory situation, one of the founder members of ASIC had

previously established QISAN to work on behalf of students, their parents, sponsors,

colleges and agents in order to address some of these concerns and to ensure that

students receive the best possible advice and assistance with their college and visa

applications and travel arrangements at a reasonable cost. The aim was to ensure,

equally importantly, that students could be confident that they will attend a reputable

college offering high quality academic programmes and full student support.

It is intended that ASIC will be a not-for-profit Company, which will undertake

accreditation of colleges by inspectors/assessors, who have a wealth of relevant

experience, under the guidance of the Advisory Board. While the assessment leading

to accreditation will cover the whole range of facilities, resources and activities of the

colleges (see Areas of Operation below), there will be a focus on the whole student

experience and staff development relevant to this, which will be guided by the

knowledge and experience gained by QISAN over the past three or four years.

The student experience is seen as beginning with the recruitment and admission

processes and these will be subject to particular scrutiny, including a review of

systems for the appointment and management of agents and of the criteria used in

assessing student applications. Similarly, there will be careful evaluation of the

systems for monitoring the effectiveness as well as the frequency of student

participation in the courses on which they are enrolled. A major element of

accreditation will be to ensure that the colleges have efficient and transparent methods

of tracking international students’ performance and attendance and that they have

systems in place to inform the Border and Immigration Agency (Home Office) of

non-compliance.

The accreditation will initially assess the college’s ability to meet the Home Office’s

minimum criteria for acceptance on the DfES’s Register of Education and Training

Providers (see Appendix 1). Indeed, the recognition of ASIC as an accrediting body is

based on its ability to reassure the Home Office that these criteria are being met.

In order to satisfy the needs of other stakeholders as mentioned above, ASIC has

identified the following Areas of Operation, which will each be assessed and given a

grade of Commendable, Satisfactory or Unsatisfactory. These grades will not only be

taken into account in deciding whether or not to award accreditation to a college, but

will also be helpful in enabling students to make informed choices on where they

might study.

Areas of Operation:

A. Premises and Health and Safety

B. Management and Staff Resources

C. Learning and Teaching; Course Delivery

D. Quality Assurance and Enhancement

E. Student Welfare

F. Qualifications and Awards

G. Marketing and Student Recruitment

H. Compliance with UK Border Agency (UKBA) Regulations and Reporting

Mechanisms.

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Also, in the interests of transparency, ASIC will host a dedicated website (Appendix

2), which will highlight key aspects of a college’s inspection report, as it is felt that

this will also be beneficial to students and their parents in helping with the decision-

making process. This will, of course, also be accessible to others including

government bodies and other sponsors, which may award scholarships to students.

Further development of the site will include student comments, relevant international

news and information from bodies such as the Home Office and British Council.

As ASIC is keen to encourage the private colleges to develop a student-centred

approach to their operations, it is suggested that the colleges may wish to consider

applying to become members of UKCISA for guidance in this respect.

Ongoing development with the accredited colleges will incorporate training

programmes on topics such as high-quality and ethical student recruitment methods,

recruiting and monitoring the work of agents, development of admission systems and

assistance in the development of codes of practice and ethics policies.

Such activities will be funded through the accreditation annual fee (see Section 7).

Accredited Colleges are entitled to use the ASIC logo and any promotional materials

produced by ASIC as long as they retain their accreditation. In the event of a college

terminating its membership of ASIC or having its accreditation withdrawn, the

college will be deemed to have given an implied undertaking to ASIC that its logo

and promotional materials will not be used further.

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3. Accreditation

3.1 Introduction

ASIC is an independent body, recognised by the Border and Immigration Agency

(Home Office) and approved by Ofsted, which provides an accreditation service for

independent further and higher education colleges.

ASIC accreditation gives reassurance to potential international (overseas) students,

their parents and education representatives that the operation of their chosen college

conforms with relevant United Kingdom laws and offers genuine courses, which are

delivered to appropriate standards with acceptable quality, and which lead to

recognised qualifications. Accreditation also provides reassurance to the Border and

Immigration Agency that the college meets their requirements (section 4.2 H) and, in

general, does not harm the perceived quality of the United Kingdom education

provision.

Accreditation is based upon the on-site inspection of the full range of the college’s

provision and supporting activities, together with a detailed consideration of the

college’s external (statutory) and internal documentation, which helps to ensure that

the ongoing operation of the college is maintained at an acceptable level.

In general, ASIC will consider applications for accreditation from colleges which

offer full-time courses (typically lasting 30 weeks per calendar year with 15 hours’

tuition per week) leading to awards, which may be “internal”, that is the college’s

own awards, or “external”, such as those validated by professional/examining bodies

or UK universities and moderated by external examiners or assessors. The

accreditation process also includes a consideration of whether or not the academic

level of internal awards is appropriate to enable the students to progress to further

study within the college or elsewhere in the UK, or to relevant employment. Colleges

are strongly recommended to involve experienced external moderators in the

assessment of their internal courses to ensure that this is the case.

Colleges delivering courses leading to awards and degrees from overseas institutions

may also be accredited provided that the awarding bodies are formally recognised as

being bona fide (see Areas of Operation).

3.2 The Accreditation Process

Colleges considering accreditation by ASIC should download an Application Form

from the website, which should be completed and returned together with copies of the

statutory (external) and college’s documentation as detailed in the Application Form

(relevant websites are listed in Appendix 3).

There are then three stages in the accreditation process, namely:

Stage 1 – Scrutiny of the Application Form and the Accompanying Documentation.

If the information provided, which is assessed by a member of the ASIC

Accreditation Committee, that is, the Assessor, is acceptable the process moves to

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Stage 2. If it is not acceptable, the college may be advised either on actions to take to

rectify the perceived shortcomings, or that it is unlikely that ASIC would accredit it at

this stage of its development. There is a fee payable at Stage 1 (see Section 7).

Stage 2 – Initial Inspection Visit

Will normally comprise a one day visit by an ASIC Inspector, who will focus on the

college’s compliance with statutory and the Border and Immigration Agency’s

requirements, management, student support, premises and the adequacy of the

teaching resources for the advertised courses. The visiting inspector will also discuss

the format of and the arrangements for the Stage 3 inspection visit with the Principal*

and senior management of the college.

However, if the college has recently been accredited by a recognised body, it may be

possible to avoid the need for a Stage 2 visit. In this case any queries or clarification

which might be required can be resolved by telephone or e-mail.

When a Stage 2 visit has occurred, the visiting inspector will submit a report of the

visit, which will recommend whether or not to proceed to Stage 3 and identify any

shortcomings that the college may need to address before the Stage 3 event takes

place.

The Stage 2 report will be considered by the Accreditation Committee (see section

3.6), which will decide whether or not to confirm the recommendations. If it is

decided not to proceed to Stage 3, the college will be informed of the reasons for this,

help in rectifying the shortcomings will be offered, the college will be given the

opportunity to appeal and present grounds for requesting a review of the inspector’s

report.

There will be a fee for the Stage 2 visit (see Section 7).

Stage 3 – Accreditation Inspection Visit

The college will be contacted regarding the arrangements for the Stage 3 inspection

visit; should the college not agree a date for this within six months of the Stage 2 visit

the application will be deemed to have lapsed.

While all eight Areas of Operation, identified in Section 1 and downloadable from our

website, will be covered during the inspection, there will be an emphasis on academic

matters, including learning and teaching, resources and quality management, together

with student welfare and reporting mechanisms (links to the UKBA). The inspectors

will also ensure that the college has responded satisfactorily to issues raised during

Stage 2. In general inspectors will seek to encourage colleges to look for ways in

which they might continue to improve their provision and suggest ways in which this

might be achieved.

* The term Principal has been used throughout for the Head of the College.

The inspection will normally last two days, though for small colleges with fewer than

200 ftes and a limited academic programme this may be reduced to one day. The

number of inspectors involved will depend on the size of the college and diversity of

the academic programme but there will be a minimum of two and a maximum of

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three. As a general guide, colleges with fewer than 1,000 ftes and not more than six

courses will be visited by two inspectors while larger and more diverse colleges will

be visited by a team of three. One of the inspectors will be designated as the lead or

Reporting Inspector with responsibility for writing the report of the whole

accreditation process including the findings of the Stage 3 visit, while the other

inspector(s) will be designated as Supporting Inspector(s).

The report will cover each of the eight Areas, identifying points of strength and of

weakness, which should be addressed. The report will summarise these under the

heading “Recommendations to the College”.

The inspectors will recommend a grade of Commendable, Satisfactory or

Unsatisfactory to each Area, which helps to determine the outcome of the inspection

and accreditation process as a whole (see Section 3.3).

There will be a fee for the Stage 3 visit (see Section 7).

3.3 Accreditation Decisions.

The final report encompassing the findings from the Stage 3 visit will be considered

by the ASIC Accreditation Committee, which will determine one of the following

outcomes:

- award accreditation for a total period not exceeding four years, after which

accreditation must be renewed,

- refuse accreditation either on the grounds that the inspectors believe that the

college does not meet the requirements for being placed on the Register of Tier

4 Sponsors (Students) under the Points based System of immigration, or that

there are other serious shortcomings in provision, in which case the college has

the right of appeal, the procedures for which are set out in Section 6,

- defer a decision when it is perceived that there are weaknesses in the college’s

provision which it is felt could be rectified in a period not normally exceeding

three months. Typically, the college will be given a number of conditions to meet

and when it is believed that these have been met there will be a further visit to

the college to confirm that that is the case.

As outlined earlier, the accreditation process will involve the consideration and

assessment of eight identified Areas of the Operation of the college as a whole. These

Areas, which are not, of course, independent of one another, are:

A. Premises and Health and Safety

B. Management and Staff Resources

C. Learning and Teaching; Course Delivery

D. Quality Assurance and Enhancement

E. Student Welfare

F. Awards and Qualifications

G. Marketing and Student Recruitment

H. Compliance with UK Border Agency (UKBA) Regulations and

Reporting Mechanisms.

9

Detailed descriptions of these areas are downloadable from our website.

The grades, which can be attributed by the Stage 3 inspectors to each of these areas,

are:

Commendable - representing good practice and a very good level of provision

Satisfactory - representing generally satisfactory practice and a level of

provision, which meets the expected threshold standards for

accreditation identified in the detailed descriptions of the areas

of operation. Some minor shortcomings in provision may be

acceptable, but the essential conditions specifically relating to

immigration have been met.

Unsatisfactory - representing weak/unsatisfactory practice with significant

weaknesses, which do not meet the expected threshold standards.

To be awarded full accreditation for a period of four years, colleges must normally

obtain at least a satisfactory grade in each area of assessment. Accreditation may still

be awarded, however, if colleges fall just below the expected threshold standard in not

more than two areas other than Learning and Teaching, Student Welfare and Quality

Assurance providing the identified weaknesses can be addressed quickly.

Colleges with unsatisfactory grades in any of the three areas identified above, or

which do not operate within statutory requirements in any area, are unlikely to be

granted accreditation.

Colleges which do not meet the requirements of the UK Border Agency will not be

granted accreditation.

Colleges which are deemed by the Accreditation Committee to have satisfied a

number of indicators of commendable provision in identified sub-areas in each Area

of Operation will be awarded a commendable grade for that Area and those colleges

which are awarded commendable grades in at least six Areas, normally including

Areas B, C, D and E, will be awarded Commendable overall. These colleges will have

ASIC Premier College status.

3.4 Continuing Accreditation

To be considered for accreditation, colleges must agree that they will submit regular

(annual) reports on their on-going operation as outlined below in Section 3.5, receive

a one day interim visit during the four year accreditation period and be prepared, if

selected, to receive a random, unannounced visit to confirm that the requirements of

accreditation are being maintained.

It is likely that the interim visit will be brought forward, or a second visit arranged, if

there are significant changes in the operation of the college, such as a change of

ownership, appointment of new senior staff, introduction of new courses affecting

more than 30% of the enrolment or a major expansion of the premises is planned.

10

A visit will also take place if any genuine complaints about the college are received

by ASIC (or a Government Body) in an attempt to resolve the complaint satisfactorily

and expeditiously. The Complaints Procedures are presented in Section 5.

If the college declines to provide regular reports or to receive any of the visits

identified above then accreditation will be withdrawn and the UK Border Agency

informed.

ASIC will endeavour to minimise the number of visits to colleges between

accreditation and re-accreditation. It is important to emphasise, however, that it is a

condition of ASIC’s recognition as an accrediting body by the Border and

Immigration Agency that it will investigate any genuine complaints about the colleges

they have accredited, especially if these relate to immigration requirements.

Whether or not the UK Border Agency is the complainant, ASIC will inform the

Border and Immigration Agency of the progress and outcomes of the investigation.

Colleges may lose points on the Register of Sponsoring Institutions, which will be

introduced in the near future, if they decline to collaborate with the investigation or

are found to have been complicit in a breach of the visa requirements. Colleges, which

have knowingly allowed such a breach to occur, will have their accreditation

withdrawn, with no right of appeal and the Border and Immigration Agency informed

accordingly.

There will be no fees or expenses payable for interim visits, random visits and visits

arising from complaints.

3.5 Annual Reports

Colleges which have been accredited are expected to submit an annual report

commencing one year after the date of full accreditation. The report should include:

Statements from the college Principal

a) confirming the college’s continued compliance with statutory

requirements,

b) confirming the college’s continued financial viability, attaching the latest

set of audited accounts, and

c) identifying any significant changes in the operation of the college, such as

change of ownership, changes in senior management, location of main

accommodation or changes in course provision.

Details of the courses delivered in the previous year, including numbers of

enrolled students and pass rates.

An outline of planned developments in accommodation, course provision or

links with other awarding bodies.

Details of any other issues which may impinge on the accreditation of the

college.

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3.6 The Accreditation Committee

The Accreditation Committee will make all decisions regarding the award of

accreditation, continuing accreditation and the withdrawal/suspension of accreditation

on the basis of a) evidence provided by the Reporting Inspectors following inspection

visits, b) evidence arising from the consideration of complaints and appeals and c)

documentation provided by the colleges themselves.

ASIC will endeavour to arrange meetings of the Accreditation Committee at least

monthly, but also as and when required in the interests of dealing with colleges’

applications within reasonable timescales. It is intended that the time which elapses

from the receipt of a college’s completed Application Form until the final decision on

accreditation is forwarded to the college should not normally exceed three months.

In addition to making decisions regarding colleges’ accreditation, the Committee will

meet regularly, normally annually, to review ASIC’s conditions for accreditation and

any alterations in statutory regulations (which will be forwarded to the accredited

colleges and those seeking accreditation).

The Accreditation Committee will normally by Chaired by the Head of Accreditation

or a Deputy Chair appointed from the Committee.

The membership, in addition to the Head of Accreditation, will comprise the Chief

Executive (or his/her nominee), the Qualifications Advisor, the Senior Inspector, the

Accreditation Advisor, the Accreditation Manager and one other experienced ASIC

Inspector, appointed by the Chair and Chief Executive, together with appropriate,

experienced co-opted members.

The quorum for meetings will require the Chair and Chief Executive and/or the

Deputy Chair to be present along with a minimum of two other members. The

Reporting Inspectors will not be required to attend unless the decision is likely to be

contentious. This arrangement will ensure that, in the event of an appeal, members of

the Accreditation Committee, who were not involved in the original decision

concerning the college, can become independent members of the Appeals Committee

as described in section 6.2.

The Accreditation Committee may delegate authority to the Chair and/or Chief

Executive to take decisions on progression from Stage 1 to Stage 2 and from Stage 2

to Stage 3 which will be ratified at a subsequent meeting of the Committee.

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4. Inspection Schedule

4.1 Introduction

As described in Section 3, the accreditation process includes one or more visits to

colleges, which are applying for accreditation, by ASIC inspectors, who will meet

relevant staff, inspect premises, observe course delivery, meet students and verify

documentation.

All ASIC inspectors must confirm before they undertake a visit that there would be no

conflict of interest involved, that all information they receive will be regarded as

strictly confidential and that they will conduct the inspection in a courteous and

professional manner following the ASIC code of conduct. The college will be

informed of the identity and background of the inspectors before the visit and

provided with a copy of the code of conduct.

The general nature of Stage 2 and Stage 3 visits is outlined in Section 3.2, where it is

indicated that Stage 2 may involve a visit by one inspector for one day, while Stage 3

will normally involve at least two inspectors for two days. A third inspector may be

required for visits to larger colleges (more than 1,000 ftes) or those with a diverse

academic programme.

While relatively little preparation is required for a Stage 2 visit (after receipt of the

Application Form and accompanying documentation), Stage 3 visits are more

comprehensive as described below.

Colleges are asked to inform all staff and students of the impending visit, to indicate

that some staff and students will be required to meet the inspectors and that some

teaching sessions will be observed.

The main purposes of the Stage 3 inspection are to assess what is observed during the

visit and to consider the evidence regarding the college’s ability to maintain and

indeed raise standards in the long term. Consideration of the documentation provided

before the visit will help in this respect and also, along with the Stage 2 inspection

report, helps the inspectors to identify issues within the eight Areas of Operation,

downloadable from our website, which will be discussed with key staff.

The precise format of a Stage 3 inspection visit is likely to vary in relation to the size,

nature, location and complexity of the college, though the likely format will be agreed

during the Stage 2 visit or by correspondence between the Principal and ASIC staff. It

is expected, however, that the inspectors will:

meet the Principal,

hold an introductory meeting with all staff if possible, or with senior staff, to

introduce themselves and outline the nature of the inspection,

undertake an initial tour of all of the premises,

undertake a detailed survey of the library,

assess the IT provision for staff and students,

assess laboratory and audio visual equipment,

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visit the refreshment areas,

meet a representative group of staff without senior managers being present,

meet course/subject leaders,

observe a number of teaching sessions (and provide informal feedback after

the observation),

meet a representative group(s) of students without any staff being present,

hold a final meeting with the Principal to give an informal report of their

findings, but not indicating the likely outcomes of the visit and whether or not

accreditation would be granted since the final decision will be made by the

Accreditation Committee. Furthermore the Reporting Inspector should

indicate that he/she has been instructed not to enter into further dialogue with

the Principal at this juncture.

The college will be asked to provide a suggested itinerary for the visit and meetings

together with full timetables for all classes taking place during the inspection. The

Reporting Inspector will consider these when allocating duties to members of the

inspection team. The precise details of the visit, however, may be changed during the

initial meeting with the Principal.

The college should also identify the staff that the inspectors are likely to wish to meet

for more detailed discussions, but it is expected that these would include:

The Principal,

Heads of Department/Course Leaders,

College Manager/Safety Officer,

Senior Administrator,

Librarian,

IT Manager/Head of Facilities,

Examinations Officer,

Accommodation Officer,

Student Welfare Officer.

Finally, it is suggested that in preparation for the Stage 3 visit the college may find it

useful to undertake a “self critical review or audit” of its total operation ( see for

example, The Ofsted Handbook for Inspecting Colleges and the Education

(Independent School Standards) (England) Regulations 2003 a Self Audit Checklist

for Schools.)

4.2 Areas of Operation

To gain a satisfactory threshold accreditation, colleges must normally be deemed to

satisfy each of the paragraphs in all eight Areas of Operation.

Colleges which are deemed to satisfy a stipulated number of the indicators of

commendable provision (listed at the end of each Area of Operation and marked *

throughout the document) and hence achieve a commendable grade for five of the

Areas of Operation, normally including Areas B, C, D and E, will be awarded

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accreditation with the grade of Commendable overall. Those colleges will have

Premier College status.

For more information on our Areas of Operation, simply download them from our

website.

5. Complaints

5.1 Introduction

ASIC takes complaints seriously and will make every effort to mediate and

recommend solutions that are mutually satisfactory for both the parties involved.

ASIC however also encourages students to carefully look at the college’s refund and

complaints procedure thoroughly before signing to the course to avoid any future

misunderstandings.

5.2 How ASIC deals with complaints:

Each complaint is logged by staff and receipt is acknowledged,

We will check the documents submitted and if further documents are

required we will contact the complainant and ask for them,

We will contact the institution and ask them to investigate the complaint

and provide details within 10 working days and then we will look into

whether the college has followed its accreditation commitments or not,

ASIC will inform the complainant of the outcome and any

recommendation that would have been made to the college.

In order for ASIC to look into a complaint the following documents should be

submitted:

A written complaint giving full details of the nature of the complaint and

evidence to support it such as the college’s response to their complaint or

proof that a complaint was made to the college,

Receipts of payments to the college, please note bank statements will not

be accepted,

Any other documents/evidence to support the complaint,

ASIC may also ask for additional documents to help further investigate the

complaint.

The following are situations that ASIC will not be involved in:

Complaints that are not relevant to the ASIC accreditation,

Where a student has failed to follow the college’s complaints procedure,

Complaints that are made anonymously, by telephone or email. All

complaints need to be in writing with evidence and details of the

complainant such as name; address; telephone number and email address

(if available) and signature,

Where not enough evidence to support the complaint has been submitted,

Where a student has sought legal advice/commenced legal proceedings

against the college,

Where there is a contractual agreement between the college and its

employees,

Where a student has entered into a contractual agreement with the college

that negates the college’s refund procedure,

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Where a student has failed to establish the relevance of the course to their

needs or establishing that the awarding body is recognised before

enrolment.

The procedures detailed above ensure that the complaint is genuine and, similarly,

complaints received from or via the UK Border Agency will need to be authenticated.

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6. Appeals

6.1 Introduction

It is recognised by ASIC that colleges, which have been refused accreditation or

which have had their accreditation withdrawn or suspended, should have access to a

fair and expeditious appeals process.

If the Accreditation Committee decides to refuse or withdraw accreditation, the Chief

Executive of ASIC will contact the college within 10 working days informing the

Principal of the decision and the reasons for it and, furthermore, reminding him/her of

the right of appeal.

The Principal, or other appropriate representative of the college, should submit an

appeal within a further 10 working days of receipt of the notification of the

Accreditation Committee’s decision. If the appeal is made by an accredited college,

then accreditation will remain in force until the appeals process is completed.

A college may have its accreditation suspended during the period of their

accreditation if serious compliance concerns are raised from various sources, which

may include UKBA, unannounced inspection visits, substantiated complaints from

students/staff. ASIC will then undertake investigations which can include

unannounced inspection visits, and accreditation may be suspended for a period of 28

days pending further investigation.

If our concerns have not been addressed satisfactorily the Accreditation Committee

will withdraw the college’s accreditation.

Colleges which have their accreditation suspended or withdrawn may appeal as

described in Section 6.2 of the Accreditation Handbook.

6.2 Procedures

If the college’s application for accreditation is rejected after the Stage 2 accreditation

visit, the Principal may request that the report of the inspection visit should be

reviewed and that additional documentation, responding to the reasons for rejection,

may be submitted.

The Accreditation Committee, including members not present at the original meeting

which rejected the application, will review the report and consider any new

documentation.

If the Accreditation Committee upholds the appeal, then the accreditation process will

proceed to Stage 3.

If, however, the Accreditation Committee upholds the original decision then the

college has the right of appeal as described below.

A college wishing to appeal against rejection of its application for accreditation after

the Stage 2 visit and subsequent review (as described above) or after the Stage 3

inspection visit, or against withdrawal of its accreditation for whatever reason, may

18

request a hearing by an Appeals Committee of ASIC. The Appeals Committee will

comprise Members of the Accreditation Committee and/or Inspectors who were not

involved in the original decision.

The appellant should submit a statement setting out the grounds for the appeal,

together with any relevant additional documentation, within 15 working days of

notification of the intention to appeal. The Appeals Committee will then endeavour to

meet not later than 15 working days after receipt of the appeal.

The college has the right to be represented at the meeting, which will also be attended

by the Chair of the Accreditation Committee.

The Appeals Committee may decide to:

- dismiss the appeal,

- order a new inspection of the college at ASIC’s expense,

- instruct the Accreditation Committee to grant or restore accreditation.

The Chair of the Appeals Committee will submit a report of the meeting to the Chief

Executive of ASIC giving the grounds for the decision and making any other

recommendations, which the Accreditation Committee should consider.

At this stage the college has no further rights of appeal. Colleges which submit an

appeal as described above will be required to pay a fee towards the costs of the

Appeals Committee’s meeting. This fee will be refunded if the Appeals Committee

instructs ASIC to award or restore accreditation.

19

7. Fees and Expenses for Inspection Visits and Accreditation (UK Only) (For International Institution fees please contact the ASIC office by phone or email)

7.1 Application for a New Accreditation

Stage 1 - submission of the Application Form and associated documentation,

£300.

Stage 2 - one day inspection visit,

£1200 + £350 per inspector day (to be included with the application).

Stage 3 - two day inspection visit,

£1200 plus £350 per inspector day, normally a minimum of four and

maximum of six days, though this may be reduced to two for very small

colleges.

Fees for colleges which have previously been accredited by a recognised accrediting

agency or for re-accreditation will be:

Stage 1 - application form - £200.

Stage 2 - the one day inspection will not normally be required.

Stage 3 - two day inspection visit - £1200 plus £350 per inspector day.

7.2 Interim Visits

There will be no fees for one day interim inspection visits, random, unannounced

visits or inspection visits made in relation to complaints or appeals.

Colleges making an appeal will, however, be required to pay a deposit of £1000 for a

full appeal or £750 for a review appeal, which will be refunded if the appeal is

successful.

7.3 Annual Accreditation Fee.

The annual fee will depend on the number of full time equivalent students there are in

the college as follows:

- up to 200 ftes : £1000,

- 200 to 400 ftes : £2000,

- over 400 ftes : £3000.

The first annual fee will be due immediately after accreditation is announced.

20

7.4 Payments of Fees and Expenses

Colleges are normally required to have paid all of the fees and expenses associated

with their application for accreditation before the final outcome of the application is

released. Colleges which do not conform with this requirement or which delay

payment of the annual fee by more than three months will be assumed to have

withdrawn from the accreditation process and will not be awarded accreditation or

have their accreditation withdrawn as appropriate and the Border and Immigration

Agency (Home Office) informed accordingly.

Once an application has been received and fees have been paid to ASIC, there will be

no fee refund under any circumstances.

Please note:

1. All cheques need to be made payable to ASIC.

2. For International Institution fees please contact the ASIC office by phone or email.

21

Appendix 1

Excerpt from the Register of Education and Training Providers in the UK.

This excerpt concerns Guidance on the Immigration Rules, with which colleges

wishing to be placed on the Register have agreed to comply. The Rules require that

for students seeking visa entry colleges will:

maintain satisfactory records of enrolment and attendance of students

provide courses which involve a minimum of 15 hours of organised

daytime study per week

ensure a suitably qualified tutor is present during the hours of study to

offer teaching and instruction to the students

offer courses leading to qualifications recognised by the appropriate

accreditation bodies

employ suitably qualified staff to provide teaching, guidance and

support to the students

provide adequate accommodation, facilities, staffing levels and

equipment to support the numbers of students enrolled at the

institution, and

comply with the latest Border and Immigration Agency guidance on

notification of absent students.

NB Failure of a college to comply with the criteria may lead to removal from the

Register and the consequent refusal of visas to students seeking to enter the UK, in

which case ASIC would withdraw the accreditation of the college.

22

Appendix 2

Accreditation Service for International Colleges – Website

In order to ensure that students, parents and representatives/agents are able to gain a

clear picture of a college that the students are considering attending, ASIC will

produce a website which will give an independent report on accredited colleges which

will be an abridged version of the inspector’s report.

ASIC will also, with the permission of the students concerned, include comments

from students interviewed during the inspection process.

This will be similar to the process used by Ofsted to inform the general public of the

outcomes of the inspection of schools & colleges in the UK.

The website will also include useful information regarding studying overseas together

with opportunities for international students to apply for scholarships through ASIC.

It is hoped that the website will be interactive so that students and colleges themselves

may add information relevant to prospective students.

ASIC will seek to attract sponsors with an interest in international education and will

also link with other relevant websites in order to achieve a high ranking on the various

search engines.

ASIC will not allow accredited colleges to advertise on this website, although a listing

with links to the websites of the colleges will be provided.

23

Appendix 3

Useful Web-sites and Contact Points

Premises and Health and Safety

Advice on occupational health and safely is available from the Health and

Safety Executive: www.hse.gov.uk

There is also an on-line service, HSE Info line: hse.infoline@natbrit.com

Fire safety guidance is available from the Fire Protection Association:

www.thefpa.co.uk

The London Fire Brigade has a down-loadable guide to Fire Safety at Work:

www.london-fire.gov.uk

Management and Staff resources

Guidance on safe and legal employment procedures is available from the

Arbitration and Conciliation Advisory Service: www.acas.org.uk

This Web-site provides model pro-formas for most aspects of employment.

Advice on copyright is available from the Copyright Licence Agency Ltd

(CLA): www.cla.co.uk

e-mail: education_customers@cla.co.uk

Student Welfare

If you handle personal information about individuals, you have a number of

legal obligations to protect that information. The Information Commissioners

Office (ICO) is available to help you understand these obligations and keep you

updated as and when they change: www.ico.gov.uk

Advice on the employment of staff who will be in contact with young people

under the age of 18 is available from the Criminal Records Bureau (CRB):

www.disclosure.gov.uk Tel: 0870 9090811

In order to provide immigration advice to prospective students, colleges must

be registered with the Immigration Services Commissioner. The Code of

Standards and Rules is available from the Office of the Immigration Service

Commissioner: www.oisc.org.uk

Guidance on visas for students is available from the UK Visas web-site:

www.ukvisas.gov.uk

The Immigration and Nationality Directorate (IND) provides form FLR(S),

used to apply for visa extensions, downloadable from:

www.ind.homeoffice.gov.uk, Enquiries may be addressed to the IND at: Lunar

House, 40 Wellesley Road, Croydon, CR9 2BY Tel: 0870 6067766,

e-mail: indpublicenquiries@ind.homeoffice.gov.uk

Information on the requirements placed on education institutions by the

Disability Discrimination Act 1991 can be found on: www.disability-gov.uk or

on the web-site of the Disability Rights Commission, www.drc-gb.org

Colleges which provide or arrange accommodation for students under the age

of 18 will be in the category of Independent Boarding Schools under The

Children Act (Section 87). The Commission for Social Care Inspectorate carries

out accreditation inspections based on a list of minimum standards for boarding

schools. Guidance on this is available from The Boarding Schools Association:

www.boarding.ofg.uk

24

Awards and Qualifications

Information on US degrees and institutions accredited by the Council for

Higher Education Accreditation is available from: www.chea.org

25

Appendix 4

A Note on Plagiarism

Academic misconduct has become a major problem worldwide in educational

institutions ranging from the most prestigious universities to small, private colleges

and schools.

Academic misconduct includes cheating in examinations whereby students seek to

gain an unfair advantage by, for example, introducing unauthorised materials, copying

from other candidates and attempting to impersonate or be impersonated as well as

plagiarism, which is perhaps the most difficult to guard against and detect.

A definition of plagiarism might be of the form “to deliberately take and use

another person’s invention, idea or writing and claim it, directly or indirectly, as

ones own”.

Some common forms of plagiarism are:

stealing, borrowing or buying, perhaps from online sources, assignments and the

like,

copying, cutting and pasting text from sources on the internet,

copying from a book or other published article, without proper

acknowledgement or referencing,

quoting word for word, lifting text (or computer programs, music, design, etc)

from others including fellow students, and

submitting this as ones own work.

Even with the definition and examples quoted above, one of the problems for

students, especially those who are non-native English speakers, is to recognise exactly

what does and what does not constitute plagiarism.

Colleges, therefore, are advised to give clear guidance to students on how to avoid

plagiarism by correctly acknowledging and referencing sources of information and

how to summarise and paraphrase and express in their own words information that

they have quite properly gathered from the internet, texts and other sources in their

preparation to complete assignments. Furthermore, students should be encouraged, if

they are in any doubt as to whether or not they have inadvertently plagiarised, to

consult their tutors for guidance.

Regrettably, despite the best efforts of colleges to warn their students of the dangers

of plagiarism and instruct them on how to avoid it, many students choose deliberately

to commit plagiarism. Tutors are therefore faced with the problem of detecting this,

which, given the huge volume of printed work can be difficult and time consuming.

Fortunately, there are now electronic ways of detecting plagiarism, including a facility

on google and “turnitin”, which is more user-friendly and effective as it can scan a

CD containing a whole assignment, dissertation or thesis to detect the amount of

plagiarised work included. There is, however, an associated financial cost to the

colleges using this system, which is completely Web-based. There is evidence that

plagiarism in colleges which are known to use electronic detection systems is much

reduced.

26

Finally, it is imperative that colleges have a policy regarding the penalties for

cheating/plagiarism not only to deter dishonest students seeking an “illegal”

advantage but also to reassure honest students that the assessment processes are fair.

It is up to each college to decide on its own range of penalties, but commonly these

range from guilty students failing the whole module/subject of which the plagiarised

assignment is a part, or perhaps, less severely, the student’s mark is reduced in

relation to the extent of the plagiarism, that is the mark for a 50% plagiarised

assignment is reduced by 50%.

Repeated plagiarism or cheating is usually considered as being much more serious

with more severe penalties including expulsion from the college.

References:

Carroll J. A Handbook for Deterring Plagiarism in Higher Education, 2002 Oxford

Centre for staff and Learning Development, Oxford.

Davis U.C., University of Southern California, Avoiding Plagiarism: Mastering the

Art of Scholarship.

http://sja.ucdavis.edu/avoid.htm October 25, 2001

Northedge A. The Good Study Guide, 1988, The Open University Press, Milton

Keynes,

turnitin http://www.turnitin.co.uk

27

Appendix 5

Code of Ethics – Colleges

1. The marketing of education services overseas should be consistent with the

maintenance of academic standards and the safeguarding of the interests of

both institutions and international students.

2. Institutions should promote accurately and honestly educational programmes

in terms of quality, standing and availability.

3. Institutions should have a clearly enunciated policy for all staffs,

representatives and agents with respect to the promotion and marketing of

education services overseas.

4. Institutions should acknowledge the need for good practice to ensure fairness

in their promotion and marketing of educational services overseas with regard

to :

4.1 Other institutions

4.2 The interests of both local and international students

4.3 The perceived quality of the education

4.4 The cultural and educational relationships among the countries

5. Differences among institutions should be portrayed in a comprehensible and

accurate way so as to project a cooperative marketing image to the target

countries. No false or misleading comparisons should be drawn with any other

provider.

6. Selection criteria for international students should be such as to maintain the

institution’s academic standards and to encourage high success rates.

7. Institutions should recognize on-going responsibilities for the education and

welfare of international students, ensuring that the academic programmes,

support services and learning environment offered encourage a positive

attitude towards the institutions.

8. Institutions should establish an appropriate infrastructure to be the focal point

for all enquiries and to ensure both the effective implementation of the

institutions’ international students programme and the provision of all

necessary support services.

9. Institutions should provide to prospective international students accurate and

comprehensive information on the institutions admission requirements and

procedures, the courses available, tuition and living costs, living conditions,

accommodation and other services. Advertisements and promotional literature

should not include misleading or ambiguous statements about the nature of the

course, or the cost of the award offered.

10. Staff members representing institutions overseas should be carefully selected

and be:

28

10.1 Sympathetic, clear communicators with a thorough knowledge

of their own institution’s courses and procedures

10.2 Sensitive to the culture and customs of the target country, and

aware of its historical and political background and educational

systems

10.3 Knowledgeable, experienced and competent in the

administration of student policy and in face-to-face dealings

with students.

11. To the extent that it is relevant the spirit of this Code also is intended to apply

to institutions and their national and international partner institutions which

offer courses through twinning arrangements, distance education or other

modes.

12. Institutions should at all times conduct themselves with integrity and in a

manner that will contribute to the image of a reliable and trustworthy provider

of high quality education and training.

13. Institutions should promote themselves in a professional and ethical manner

and should ensure that all marketing activities reflect best practice.

14. Institutions should behave toward other institutions, professional colleagues

and other countries in a respectful and courteous manner.

15. Institutions should be aware of all other codes of practice and guidelines that

may have relevance to international activities and international students and

should ensure that they observe the requirements of these codes.

29

Appendix 6

Code of Ethics – Educational Representatives

1. Demonstrate appropriate attributes and abilities to competently service the

legitimate needs of international students.

1.1 Do nothing to support or encourage illegal actions

2. Maintain proper and high standards of professional conduct of business as an

international education agent by actively upholding this code at all times

2.1 Accurately represent areas of competence, education, training

and experience

2.2 Maintain the confidentiality and integrity of information about

student and communications with students. Complying with

data protection law and any policy of the adviser’s employing

organization on confidentiality and record keeping. Ensure that

information about any circumstances in which information may

be disclosed without prior authorization is available to students.

2.3 Refrain from unjustified or unseemly criticism of other

educational representatives or institutions and seek to resolve

any conflict of advice directly with the party concerned in a

professional manner.

3. Establish appropriate resources and procedures needed to provide professional

support services to international students and institutions.

3.1 In particular, keep themselves informed, as may be relevant to

their areas of advice, of developments in statutory and case law,

regulations, immigration rules and procedures, institutional

policies and other codes.

4. Be accountable to both institution and student clients

4.1 Be aware of the difference between information, advice and

counselling and be able to recommend qualified counselling

assistance to students who may benefit from it.

4.2 Recognise the boundaries of their qualifications and

competence, making appropriate referrals when situations fall

outside them.

4.3 Actively seek to promote personal professional development

and keep themselves informed of current developments in their

fields.

5. Provide student and institutions with information they need and not withhold

relevant information.

5.1 Act in good faith and with fairness, consideration and

objectivity

5.2 Providing a representative voice regarding issues that are of

importance to college programmes

6. Provide the range of services required by represented institutions to ensure co

operative delivery of quality support to international students.

30

7. Work with institutions and professional bodies as a provider quality education

agent.

7.1 Supporting and promoting college education programmes.

7.2 Promoting and providing professional development.

7.3 Prompt / timely responses to communications

8. Not discriminate, or tolerate discrimination on the part of others, on the basis

of ethnic or national origins, gender, sexual orientation, religion, disability or

age.

8.1 Be aware of, and show appropriate sensitivity to and respect

for, other cultures and value systems

9. Act in the best interests of the student, while respecting institutional policies,

statutory and legal requirements and the legitimate interests of sponsors.

9.1 Principally concerned with the personal, social, educational and

career needs of the students.

10. Educational representatives are required to advertise in an ethical manner by

not engaging in false, misleading or damaging advertising.

11. Educational representatives should continually monitor their effectiveness as

professionals and take steps to improve when necessary.

31

Appendix 7

Agreement for the Recruitment of International Students

This agreement is drawn up between:

Hereinafter called “The Representative”, the term to also mean all persons working

on behalf of/representing, whether paid or unpaid the Representative as detailed

herein).

And XXXXXXXX

Hereinafter called “XXXXXXXX.”

Both parties agree for the period of this agreement that the following shall apply:

1. XXXXXXXX, through its International Office, appoints the following

Representative in …………………………………………….. for the purposes of

providing information and data about XXXXXXXX to individuals and

organisation in ……………………………………. and to assist, support and give

guidance, to students wishing to attend XXXXXXXX for English language,

undergraduate and postgraduate studies and tailor-made programmes. It is

understood that the representative will in undertaking this take heed of the British

Council Guide to Good Practice for Education Agents and the XXXXXXXX

Code of Ethics

The British Council Guide to Good Practice for Education Agents is available at:

http://www.britishcouncil.org/ecs/agents/guidelines_for_agents/index.htm

2. This agreement takes effect from ……………………………………………and

shall, unless termination is earlier in accordance with this Agreement, continue for

an initial period of three years from the date shown, with a review being

undertaken annually. Either party may terminate this agreement by giving thirty

(30) days prior notice in writing to the other, where it considers termination

justifiable on the grounds that no further purpose would be served by continuing

the association.

3. If either party hereto shall commit any breach of or default in any of the terms or

conditions of this Agreement and also fails to remedy such a default or breach

within thirty (30) days, after written notice of such is given to either party hereto,

the party giving notice may, at its option and in addition to other remedies which

it may have under English Law, terminate the Agreement by sending notice of

such termination in writing to the other party to such effect and such termination

shall then be effective as of the date of the receipt of such notice.

32

4. Any desire to change the terms of this Agreement in any way shall be valid only if

the change is made in writing and approved by mutual agreement of the

authorised representatives of the parties hitherto stated.

5. The Representative is not in anyway authorised to act as agent for XXXXXXXX

in any other capacity or action. Neither party shall be bound by any such acts or

conduct carried out by the other within any such breach.

6. Whilst XXXXXXXX will use all reasonable endeavours to ensure the accuracy of

the information given to the Representative and other material supplied,

XXXXXXXX makes no warranty, expressed or implied, as to the accuracy and

will not be held responsible for any consequences arising out of any inaccuracies

or omissions unless such accuracies or omissions are the result of negligence on

the part of XXXXXXXX.

7. The design, text and any data of any publicity being undertaken by the

Representative, which refers to XXXXXXXX, is to be approved in advance by

XXXXXXXX. Copyright, logo and trading rights on all material shall remain

vested in XXXXXXXX and may not be used by the Representative or other

parties without the express permission of XXXXXXXX, in writing and in advance

of any usage.

8. In representing XXXXXXXX, it will be expected that the Representative will be

able to provide premises in agreed locations that are capable of representing and

maintaining the standards expected by XXXXXXXX overseas. XXXXXXXX

will make these conditions known to potential Representatives on request and will

expect such Representatives to adhere to these conditions at all times.

9. It is agreed by both parties herein that an authorised representative of

XXXXXXXX is able at some time during the agreement period inspect the

premises of the Representative used to project XXXXXXXX and its overseas

operations. A report on the visit and the findings will be made available to the

Representative for discussion with XXXXXXXX and to agree future

developments for both parties to maintain standards.

10. The Representative agrees to work with XXXXXXXX to help develop publicity

and marketing delivery in country under the direction of XXXXXXXX and as

such will make their premises available for XXXXXXXX staff visiting the

Representative’s country for such purposes. IT communications to keep in contact

with XXXXXXXX staff is a prerequisite of becoming a XXXXXXXX

Representative.

11. The representative will ensure that application forms are completed in their

entirety by the applicant.

12. XXXXXXXX’s International Office undertakes to provide for accepted and

contracted Representatives, an information pack detailing XXXXXXXX s

procedures and to provide information needed by The Representative for the

successful promotion of XXXXXXXX. The Representative will also agree to

attend any in country training that is made reasonably available to the

33

Representative by XXXXXXXX. This is to ensure that the quality of provision

and representation of XXXXXXXX and its recruitment processes are maintained.

13. As consideration for the services of the Representatives on its behalf in

…………………………., XXXXXXXX agrees to pay to the Representative the

following commission for all students demonstrably attending a course at

XXXXXXXX from work attributable to the Representative:

For English Language courses and tailor-made programmes: A payment of …%

of the tuition fees of all courses attended by any one student.

For the, International Foundation, Diploma and Pre masters a Payment of …% of

the first year tuition fee.

For all other academic programmes a Payment of …. % of the total fee paid by

the student to XXXXXXX.

This commission will however only be for those courses expressly targeted by

XXXXXXXX and agreed with the Representative in advance each year, in

writing, by the authorised XXXXXXXX representative. XXXXXXXX will not

pay the payment of VAT on top of this commission for any Representative who

operates with Offices within the UK.

14. All commission will be paid only upon receipt of student payment to

XXXXXXXX. For students who pay by instalments the University will pay the

representative on a pro-rata basis sending the commission upon payments received

to the representative at the end of each term. Representatives must send a detailed

invoice (per student) for the full amount of commission due at the beginning of

the student’s study period at XXXXXXXX , and it is against this that the Finance

office will make the commission payments as explained above. For English

Language courses, it is understood that should a student prolong the period of

their study at XXXXXXXX the International Office will inform the sending

representative about this and the representative, upon sending a new invoice for

this will be paid the extra commission due.

15. In accepting the conditions of this Agreement …………………………………...

also agree to abide by the highest possible standards and ethics in dealing

with potential customers of XXXXXXXX. They likewise agree to abide by the

ECS Code of Professional Standards and Ethics (available at:

http://www.britishcouncil.org/ecs/copse/index.htm).

16. This Agreement and all its terms, provisions and conditions and all questions of

construction, validity and performance under this Agreement shall be

governed by the Law of England and shall be subject to, as will any future

dispute arising whatsoever, to the exclusive jurisdiction of the English courts.

34

SIGNED SIGNED

On behalf of On behalf of XXXXXXXX

Name Name

Position Position

…………………………… ………………………………….

Date.……………………… Date……………………………..

This document is not legal unless both parties have signed